CRA Exam Filler

Posted By: Ryan Yager

CRA Exam Filler - 05/01/15 07:10 PM

I've got a batch of loans that I know do not qualify for Community Development. However, these loans are to different non-profits and municipalities. Do examiners look favorably on such loans even if they are not targeting LMI, or are community service, or create jobs, etc.?

Same goes for loans to small business startups.

Should I include these somewhere when being examined as "filler" ?
Posted By: Kathleen O. Blanchard

Re: CRA Exam Filler - 05/01/15 07:25 PM

Re the startups, do you mean that they are in your small business loan data but you want to point them out? You can do that. Same with the other loans. Prepare a writeup on how this lending helps your assessment area, with info on the amounts and what the benefit is. They can sometimes get a "comment" in the report and help in the rating determination.